II.C.13(c) Disposal of Information

The institution should have appropriate disposal procedures for paper-based and electronic information.See also Information Security Standards, section III.C.4., requiring each financial institution to develop, implement, and maintain, as part of its information security program, appropriate measures to properly dispose of "customer information" and "consumer information." Designating a single individual, department, or function to be responsible for disposal facilitates accountability and promotes compliance with disposal policies.

Policies should prohibit employees from discarding paper-based information containing sensitive information by using the same disposal system as regular garbage to avoid accidental disclosure. Many institutions shred paper-based media on-site while others use collection and disposal services to ensure the media are rendered unreadable and unlikely to be reconstructed. Institutions that contract with third-party service providers should conduct due diligence to ensure those third parties conduct adequate employee background checks and employ appropriate controls. Contracts with third-party disposal firms should address acceptable disposal procedures.

Electronic information and computer-based media present distinct disposal challenges. In addition to disk drives and other forms of storage, information frequently is contained in or on the memory of other devices (e.g., printers, fax machines, and cellphones). Residual data frequently remain on media, even after deletion. Because the data can be recovered, additional disposal techniques should be applied to devices containing sensitive data. Overwriting destroys data by replacing it with new, random data. Overwriting may be preferable when the media will be reused. To be effective, overwriting may have to be performed many times.

Another disposal technique is degaussing, which scrambles the data recorded on the media with powerful, varying magnetic fields. Physical destruction of the media can make the data unrecoverable. Data can sometimes be destroyed after overwriting. Management should determine the most effective method of disposal based on the type of information. Policies and procedures should address making data non-recoverable. The institution should base its disposal policies on the sensitivity of the information. Policies, procedures, and training should inform employees about what actions should be taken to securely dispose of computer-based media and protect the data from the risks of reconstruction. Management should log the disposal of sensitive media. Logs should record the party responsible for disposal, as well as the date, media type, hardware serial number, and method of disposal. In cases when such devices are rented, rather than owned, by the institution, media sanitization should be addressed contractually so that sensitive information is disposed of properly before returning equipment at the end of the rental period.


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II.C.13(b) Electronic Transmission of Information
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II.C.13(d) Transit of Physical Media